OPINION
TANNENWALD, Judge:
Respondent determined a deficiency of $24,547.47 in petitioners' Federal income tax for the taxable year ended December 31, 1979. After concessions, the sole issue for decision is what was the fair market value, on October 9, 1979, of an open-space easement which petitioners donated to the Virginia Outdoors Foundation. For reasons of convenience, we have combined our findings of fact and opinion.
Some of the facts...
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